On November 25, 2015, the Commodity Futures Trading Commission (the "Commission" or the CFTC) proposed a comprehensive set of new rules ("Regulation AT") that, if adopted, potentially would impose many new obligations on most CFTC registrants that use, or whose customers use, algorithmic trading systems (ATS) to trade futures, options or swaps on a designated contract market (but not on a swap execution facility (SEF)). The impacted registrants include futures commission merchants, introducing brokers, floor brokers, swap dealers, major swap participants, commodity trading advisors and commodity pool operators.